Opinion for the Court filed by Circuit Judge GARLAND.
GARLAND, Circuit Judge:
A U.S. Park Police officer stopped defendant Michael Davis as he was leaving Hains Point Park in Washington, D.C., in a car with a cracked windshield. After Davis made repeated movements toward the underside of the driver's seat, the officer ordered him to put his hands on the steering wheel. When Davis nonetheless continued to reach under the seat, the officer asked him to step...
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